Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
ITAT ruled in favor of the assessee, allowing exemption under Section 54F. The tribunal found that the assessee effectively owned only one residential house at the time of transfer of original asset, having gifted another property to his daughter. The tribunal rejected technical objections by the Assessing Officer regarding the gift's validity and timing of property purchase. The court determined that the assessee met substantive requirements of Section 54F, including investing capital gains in a residential house property within prescribed timelines. The land purchased was considered valid for residential construction, thus qualifying for the exemption. Consequently, the Revenue's appeal was dismissed, upholding the assessee's claim for tax exemption.
ITAT ruled in favor of the assessee, allowing exemption under Section 54F. The tribunal found that the assessee effectively owned only one residential house at the time of transfer of original asset, having gifted another property to his daughter. The tribunal rejected technical objections by the Assessing Officer regarding the gift's validity and timing of property purchase. The court determined that the assessee met substantive requirements of Section 54F, including investing capital gains in a residential house property within prescribed timelines. The land purchased was considered valid for residential construction, thus qualifying for the exemption. Consequently, the Revenue's appeal was dismissed, upholding the assessee's claim for tax exemption.
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TaxTMI 
TaxTMI 
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